1. RECIPE FOR AN EFFECTIVE VOIR DIRE 1.IMMEDIATELY BREAK THE ICE 2.INTRODUCE YOURSELF 3.POWER STATEMENT 4.ENCOURAGE JURORS TO TALK 5.BIAS AND PREJUDICE 6.START WITH AN EDUCATION QUESTION 7.DEVELOPING YOUR CHALLENGES

2. RECIPE FOR AN EFFECTIVE VOIR DIRE 8.[Pick a juror], “Even if supported by the evidence, some people could never award money for mental anguish. How do you feel about this?” IF JUROR AGREES, Thank juror and then identify the other panel members who feel the same way.

3. RECIPE FOR AN EFFECTIVE VOIR DIRE 8.[Pick a juror], “Even if supported by the evidence, some people could never award money for mental anguish. How do you feel about this?” IF JUROR DISAGREES, ask 2 or 3 more individual jurors until someone agrees. If none agree, then see who in the panel feels this way. Once a juror admits to this opinion, thank the juror and then identify the other panel members who feel the same way.

4. RECIPE FOR AN EFFECTIVE VOIR DIRE 8.[Pick a juror], “Even if supported by the evidence, some people could never award money for mental anguish. How do you feel about this?” Go back to the JUROR who initially agreed and ask, “On this issue, you are starting out with a leaning or prejudgment, what the law calls a bias or prejudice, fair to say?” Ask the same question to all the other jurors who had the same opinion.

5. RECIPE FOR AN EFFECTIVE VOIR DIRE 9. [Pick a juror], “Some people say they could award money for mental anguish but they could never award millions of dollars, even if supported by the evidence. How do you feel about this?” IF JUROR AGREES, Thank juror and then identify the other panel members who feel the same way.

6. RECIPE FOR AN EFFECTIVE VOIR DIRE 9. [Pick a juror], “Some people say they could award money for mental anguish but they could never award millions of dollars, even if supported by the evidence. How do you feel about this?” IF JUROR DISAGREES, ask 2 or 3 more individual jurors until someone agrees. If none agree, then see who in the panel feels this way. Once a juror admits to this opinion, thank the juror and then identify the other panel members who feel the same way.

7. RECIPE FOR AN EFFECTIVE VOIR DIRE 9.[Pick a juror], “Some people say they could award money for mental anguish but they could never award millions of dollars, even if supported by the evidence. How do you feel about this?” Go back to the JUROR who initially agreed and ask, “On this issue, you are starting out with a leaning or prejudgment, what the law calls a bias or prejudice, fair to say?” Ask the same question to all the other jurors who had the same opinion.

8. RECIPE FOR AN EFFECTIVE VOIR DIRE 10. [Pick a juror], “Some people say they could award money for mental anguish even millions of dollars, but you’d have to prove it by more than a preponderance of the evidence. How do you feel about this?” IF JUROR AGREES, Thank juror and then identify the other panel members who feel the same way.

9. RECIPE FOR AN EFFECTIVE VOIR DIRE 10. [Pick a juror], “Some people say they could award money for mental anguish even millions of dollars, but you’d have to prove it by more than a preponderance of the evidence. How do you feel about this?” IF JUROR DISAGREES, ask 2 or 3 more individual jurors until someone agrees. If none agree, then see who in the panel feels this way. Once a juror admits to this opinion, thank the juror and then identify the other panel members who feel the same way.

10. RECIPE FOR AN EFFECTIVE VOIR DIRE 10. [Pick a juror], “Some people say they could award money for mental anguish even millions of dollars, but you’d have to prove it by more than a preponderance of the evidence. How do you feel about this?” Go back to the JUROR who initially agreed and ask, “On this issue, you are starting out with a leaning or prejudgment, what the law calls a bias or prejudice, fair to say? Ask the same question to all the other jurors who had the same opinion..

11. RECIPE FOR AN EFFECTIVE VOIR DIRE 11.MANAGING THE CLOCK IS CRITICAL 12.SCALED QUESTIONS THROUGHOUT 13.NO INTERRUPTIONS DURING SCALED ANSWERS 14.ADDRESS THE DEFENSES (Yeah, …but)

12. RECIPE FOR AN EFFECTIVE VOIR DIRE 15.INNOCULATE JURORS FROM THE DEFENSE 16. CATCH-ALL QUESTIONS 17.END WITH AN EDUCATION QUESTION 18.REPEAT YOUR POWER STATEMENT